Compliance

In alignment with our corporate philosophy, "Enriching Future Society through Imaging Solutions," we have established the "EIZO Group Code of Conduct" to serve as a framework for conducting business with integrity, while maintaining a commitment to environmental sustainability, human rights, and ethical standards.
This Code communicates our commitment to sustainability, to our stakeholders, and also functions as the guiding standard for decision-making and conduct in our business activities. It is clearly communicated to all officers and employees throughout the Group.
To reinforce this Code, we established the "EIZO Group Human Rights Policy" in April 2022 and "EIZO Group Anti-Bribery and Anti-Corruption Policy" in January 2024. The "EIZO Group Code of Conduct," the "EIZO Group Human Rights Policy," and the "EIZO Group Anti-Bribery and Anti-Corruption Policy" are available in ten (10) languages. Moving forward, we will continue enhancing these initiatives in alignment with the development of our Group, our business model, and changes in the external environment.

In accordance with the "Internal Whistleblowing Rules," we have established an internal reporting system across all Group companies worldwide to facilitate the early identification and prevention of serious incidents, including legal violations and misconduct that could impact the company's reputation and value. We emphasize and communicate that the privacy of whistleblowers will be rigorously protected and that we have zero tolerance for any form of retaliation or adverse treatment against individuals who raise concerns. To ensure that the system is accessible and effective as a means for self-regulation, we continuously review and enhance its operation and update the relevant policies as needed.
Informational materials outlining the reporting process and system usage are available in multiple languages to ensure clarity and understanding among all officers and employees across the Group. Furthermore, annual compliance training sessions are conducted, which include detailed information on the internal whistleblowing system as well as guidance on how to use it. Reporting channels are accessible both internally within the organization and externally through designated law firms. All officers and employees are encouraged and required to promptly report any legal violations, misconduct, or ethical concerns encountered during their work, regardless of their personal involvement.

The response to internal whistleblowing reports is handled by the Chief Compliance Officer and the General Affairs Department (Legal & Compliance Section).
(1) Based on the findings of the report, the Legal & Compliance Section conducts interviews with relevant parties to verify the facts. If a legal violation is confirmed, the Head of the General Affairs Department reports the matter to the Chief Compliance Officer and the members of the Audit & Supervisory Committee.
(2) During an internal whistleblowing response meeting convened by the Chief Compliance Officer, appropriate response measures and strategies for preventing recurrence are discussed and approved.
(3) The Chief Compliance Officer oversees the implementation of the approved response and prevention measures. The effectiveness of the recurrence prevention measures is reviewed quarterly over a period of one year.
(4) The Legal & Compliance Section communicates the investigation results and the actions taken to the whistleblower, excluding anonymous whistleblowers and those who have expressed a preference not to receive the results.

We became a regular member of the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) in April 2024 and are working to develop the grievance mechanisms required by the UN Guiding Principles on Business and Human Rights.
JaCER provides a non-judicial "Engagement and Remedy Platform" for the redress of grievances based on the Guiding Principles.
Through this platform, we accept complaints and reports of violations and alleged violations of human rights and other responsible business conduct from a wide range of external stakeholders, including our global supply chain.

Our Group operates in a complex regulatory environment worldwide. Ensuring compliance with applicable laws and regulations, as well as providing ongoing training, are integral components of our compliance program.
We maintain regular communication with all our Group Companies to stay informed about local regulatory developments, enabling us to respond promptly and appropriately. We also facilitate timely training initiatives to support compliance efforts across all regions.
For our operation in Japan, the Legal & Compliance Section offers online training resources and conducts in-person training sessions at least annually for all officers and employees, including temporary staff. These sessions are designed to continuously update and reinforce compliance knowledge across key areas such as human rights, anti-bribery and anti-corruption measures, and personal data protection.
Additionally, we organize specialized training programs tailored to specific departments and levels within the organization, including new managers, leaders, and new employees, to enhance awareness and deepen understanding of our compliance standards.

EIZO Corporation and all EIZO Group companies (hereinafter referred to as the “EIZO Group”) believe that each individual must not only comply with laws and regulations but also act with a high ethical standard that exceeds societal expectations, always with integrity, fairness, and impartiality. This is fundamental to gaining trust from society and stakeholders.
To prevent bribery and all forms of corruption^*1, we hereby establish the “EIZO Group Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as the “Policy”) and commit to adhering to it.

1. Basic Policy

1. (1) We never engage in any illegal provision of benefits^*2 to public officials*3, regardless of location.
2. (2) We never engage in the provision or receipt of unlawful or socially inappropriate benefits in relationships with companies or individuals, regardless of location.
3. (3) We comply with all laws, regulations, and guidelines related to bribery and corruption in all countries and regions where we conduct business activities^*4.

2. Scope of Application

This Policy applies to all individuals working within the EIZO Group (hereinafter referred to as "Officers and Employees"). We expect our suppliers and business partners to support this Policy.

3. Prohibition of Unlawful Provision of Benefits

3-1 Provision of Benefits to Public Officials

1. (1) We do not provide benefits to public officials with whom we have business relations, especially with wrongful intent.
2. (2) We do not provide benefits that are deemed socially unacceptable, even to public officials with whom we have no business relations.
3. (3) We do not make facilitation payments^*5.

3-2　Provision of Benefits to Individuals Other than Public Officials

1. (1) We do not provide benefits to companies or individuals, including business partners, with wrongful intent.
2. (2) Even without wrongful intent, we do not provide benefits to companies or individuals beyond what is deemed socially acceptable.

4. Prohibition of Unlawful Receipt of Benefits

1. (1) We do not accept any benefits from others with wrongful intent.
2. (2) We do not accept any benefits from others that are deemed socially unacceptable, even without wrongful intent.

5. Prohibition of Conflicts of Interest

We do not engage in any actions that harm the interests of the EIZO Group, or actions that may appear to do so, in situations where our personal interests or those of a third party conflict with the interests of the EIZO Group.

6. Record Keeping

1. (1) When providing benefits to public officials or companies/individuals in a manner that does not violate this Policy, we will do so only with prior approval from EIZO Group authorities and will create and maintain accurate records of such benefits.
2. (2) To fulfill accountability for compliance with this Policy, we factually and accurately record all such transactions and archive related documentation in accordance with the internal regulations of each company within the EIZO Group.

7. Consultation, Reporting, Whistleblowing, & Cooperation with Investigations Investigations

1. (1) EIZO Group establishes appropriate consultation, reporting and whistleblowing systems to ensure compliance with the Policy by Officers and Employees, and to prevent and correct any conduct by Officers and Employees that violates this Policy.
2. (2) In the event of any actions related to bribery or other corruption, or any conduct that could lead to the suspicion of bribery or other corruption, we must immediately consult, report, or whistleblow to the reporting channels or the compliance section of each company within the EIZO Group. In addition, we will fully cooperate with any investigation conducted by the EIZO Group.

8. Implementation of Internal Education

EIZO Group regularly provides education on anti-bribery to Officers and Employees to ensure thorough awareness and understanding of this Policy.

9. Risk Assessment & Review

EIZO Group will regularly assess the risk of bribery and corruption and, as necessary, review this Policy, related internal rules, and measures based on this Policy.

Mr. Yoshitaka Jitsumori
Chairman & CEO
EIZO Corporation

January 31, 2024 (Established)
April 17, 2025 (Revised)

1. *1 "Corruption" refers to any act of abusing one's or a third party's authority to gain or provide illicit benefits. This includes, but is not limited to, bribery, embezzlement, collusion, money laundering, extortion, fraud, blackmail, insider trading, preferential treatment, facilitation payment, etc. Conflicts of interest are also considered corruption.
2. *2 ""Benefits" means any tangible or intangible benefits, direct or indirect, including financial and non-financial benefits, promises of acts or omissions expected by the other party.
3. *3 "Public Official" means an individual falling under any of the following categories:
   1. (a) Those engaged in the public service of the government or local public entities (hereinafter collectively referred to as "government, etc.").
   2. (b) Those deemed to be an official engaged in public service according to laws and regulation.
   3. (c) Those engaged in the affairs of government-related agencies.
   4. (d) Those engaged in the affairs of public enterprises granted benefits by the government, etc.
   5. (e) Those engaged in the public services of international organizations.
   6. (f) Those delegated authority by a government, etc. or an international organization to conduct its affairs.
4. *4 "Laws and guidelines related to bribery and corruption in each country, including criminal laws, company laws, unfair competition laws, the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act.
5. *5 "Facilitation payment" means small payments requested by a public official, without legal basis in relevant laws and regulations, such as an application for customs clearance, censorship, or issuance or extension of an entry or stay visa and other similar processes.